Ryan J. Kelly

Clients depend on Ryan to guide them through the intricacies of international business taxation, cross-border transactions, and complex litigation. Ryan provides his clients with responsive and thorough advice based on his extensive experience representing both multinational corporations and the U.S. government on a wide variety of domestic and international tax issues.

Advised the IRS’s Large Business & International Division from the examination phase and during litigation in a redetermination action for more than $7 billion relating to the IRS’s asserted transfer pricing adjustments under IRC Section 482. Facebook Inc. & Subsidiaries, U.S. Tax Court, No. 21959-16.

Represented the taxpayer from the examination phase to the time of litigation in a redetermination action for more than $3 billion relating to the IRS’s asserted transfer pricing adjustments under IRC Section 482. Amazon.com Inc. & Subsidiaries, U.S. Tax Court, No. 31197-12.

Represented the taxpayer from the examination phase through litigation in a redetermination action for more than $600 million relating to the IRS’s asserted transfer pricing adjustments under IRC Section 482. Medtronic Inc. v. Commissioner, U.S. Tax Court, No. 17488-08.

Represented the taxpayer from examination through litigation in a redetermination action for an alleged tax liability of $97 million in a transferee liability case. Dorothy R. Diebold v. Commissioner, U.S. Tax Court, No. 24675-07.

Represented a multinational corporation as the lead plaintiff in a class action tax refund suit seeking tax refunds of more than $8 billion for the IRS’s collection of communications excise tax. RadioShack Corporation v. United States of America, U.S. Court of Federal Claims, No. 06-28T.

Represented a multinational corporation that specializes in semiconductor design with a cost-sharing buy-in issue. The IRS proposed income adjustments of approximately $8.9 billion under IRC Section 482.

Represented a multinational automotive corporation in obtaining a bilateral advance pricing agreement from the IRS to establish the tax treatment of certain intercompany transactions.

Represented a multinational heavy equipment manufacturer in obtaining a bilateral and unilateral advance pricing agreement from the IRS to establish the tax treatment of certain intercompany transactions.

Represented two multinational corporations with the creation of a global hand and power tool company formed through a joint venture. This venture involved more than 30 tax jurisdictions worldwide.

Represented a multinational corporation that specializes in global energy management before the IRS Office of Appeals relating to the IRS’s recharacterization of intercompany loans as equity. The IRS asserted income adjustments of nearly $300 million that were fully conceded.

Ryan J. Kelly is a partner with Alston & Bird’s Federal & International Tax Group. Ryan practices in transfer pricing, tax dispute resolution, and general tax planning. He focuses on domestic and international tax issues with an emphasis on transfer pricing. Ryan has advised multinational corporations and the U.S. government on complex cross-border transactions, including several litigation matters involving tax disputes that are some of the largest in U.S. history.

Ryan previously served as an attorney-adviser in the IRS Office of Associate Chief Counsel (International), where he advised examiners, economists, and lawyers with the IRS’s Large Business & International Division on high-stakes international tax issues and transfer pricing. Before serving at the IRS, Ryan was a member of the North American tax practice group of one the world’s most global law firms. Ryan serves as an adjunct professor of law at the Georgetown University Law Center and is past chair of the Federal Bar Association’s Section on Taxation. He is also a registered U.S. merchant marine officer.

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Bar Admissions

District of Columbia

Georgia

Education

Georgetown University (LL.M., 2008)

Mercer University (J.D., 2005)

University of Georgia (B.B.A., 2002)

Memberships

Federal Bar Association Tax Section, Steering Committee

Federal Bar Association Tax Section, former chair

American Bar Association Tax Section

District of Columbia Bar Tax Section

International Fiscal Association

J. Edgar Murdock American Inn of Court, U.S. Tax Court, associate member